Comments to the State Dept on the Keystone XL pipeline Draft Supplemental Environmental Impact Statement

Climate Science Watch submitted the following comments to the State Department on the Draft Supplemental Environmental Impact Statement (SEIS) for the proposed Keystone XL Canadian tar sands pipeline. A 45-day pubic comment period ended today.

CSW comments to the State Department:

There are multiple reasons to reject the Draft SEIS as inadequate and misleading and to oppose granting a permit for the Keystone XL pipeline. Most urgently, there is an overriding ‘national interest’ in forestalling the development of a major new fossil fuel source that will exacerbate global climatic disruption and undermine the transformation of the energy system to decarbonized sources.

The most essential reason to refuse a permit for the pipeline is that granting a permit would enable the full-scale development of the tar sands -- an enormous pool of carbon that the oil industry has every intention of extracting, transporting, refining, and sending into the global market to be burned.

A policy with scientific integrity and commensurate with the magnitude and urgency of the problem of global climate disruption would call for leaving the tar sands in the ground. If the tar sands can find a way to the market, they will be fully developed. If we can’t say no to this, where will we draw the line? If we allow essentially unlimited development of fossil fuel sources, including unconventional sources such as the tar sands, what hope would there be for expediting the necessary phase-out of fossil fuels and the fundamental transformation to a clean energy system? And thus, what hope would there be for meeting the U.S. responsibility to seek to prevent disastrous climate change?

James Hansen and other leading climate scientists have been admonishing the U.S. government to consider and act on this concern. Hansen has said: “We need to limit the climate forcing severely. Moving to tar sands, one of the dirtiest, most carbon-intensive fuels on the planet, is a step in exactly the opposite direction, indicating either that governments don’t understand the situation or that they just don’t give a damn. People who care should draw the line.”

1. Difficult-to-remediate spills from the pipeline are likely and threaten to degrade and pollute land and water resources and have harmful impacts on human health and wildlife. The tar sands pipeline spill in the Kalamazoo River, which InsideClimate News recently won a Pulitzer Prize for reporting on, is an example of what could be expected from the Keystone XL.

2. The argument that the pipeline and the tar sands oil it would deliver would enhance U.S. national security and energy independence is misleading. The way to enhance national security vis-à-vis oil is to break the stranglehold of oil on the transportation system, by dramatically reducing demand and developing alternative transportation energy sources. Building new infrastructure to lock the system into producing a major new source of oil supply takes us in the wrong direction, regardless of whether the oil is used in the U.S. or exported.

3. Proponents of the pipeline have engaged in a predatory relationship with Americans’ insecurity about unemployment to present what appear to be grossly exaggerated estimates of the job-creating benefits of the pipeline.

4. There are conflicts of interest in the relationship between TransCanada and the consultants who developed the Draft SEIS, which appears to compromise the independence of the assessment.

5. The Draft SEIS tries to make the tar sands climate change impacts issue go away by contending that Canada will develop and transport the tar sands regardless of whether they do it via the Keystone XL or an alternative method. Thus, the Draft SEIS suggests it is hopeless to try to stop tar sands development. But an essential premise of the Draft SEIS, that rail transport is a viable alternative to the Keystone XL for moving tar sands from Canada to the Gulf Coast, has been challenged by independent analysis that concludes the Draft SEIS makes misleading assumptions about transportation costs. A U.S. decision on the pipeline permit is likely to play a major role in the economics of whether full-scale development of the tar sands will be expedited.